Beige packaging, a stylised leaf, a reassuring phrase: “good for the planet”. For years, this visual and verbal language was enough to give a product an eco-friendly sheen. It is becoming much riskier legal territory. With national measures transposing EU Directive 2024/825 scheduled to apply from 27 September 2026, environmental communication is entering a new phase: one of clearly defined, documented and verifiable claims. For brands, the task goes far beyond rewriting a slogan.
A European deadline, national implementation
Adopted on 28 February 2024, Directive 2024/825 aims to empower consumers to contribute to the green transition. It amends two cornerstone pieces of EU consumer legislation, covering unfair commercial practices and consumer rights. Member States were required to adopt their transposition measures by 27 March 2026, with application from 27 September.
This timetable is set by the EU legislation; the actual status of transposition and the implementing arrangements must be checked country by country. The common deadline should therefore not be mistaken for evidence of uniform application. The analysis presented here draws on the adopted directive and established developments, without presuming any subsequent national measures or court rulings.
Another essential distinction: this legislation is not the proposed “Green Claims” directive, presented in 2023 specifically to regulate the substantiation and communication of explicit environmental claims. The two initiatives have often been linked. But the obligations arising from 2024/825 must be examined in their own right, without attributing to them a general mechanism for prior approval of every claim.
Vague language loses its safe haven
The first major change is that certain practices are being added to the list of commercial practices considered unfair in all circumstances. These include generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Expressions such as “eco-friendly”, “green” or “environmentally friendly” thus become particularly sensitive.
A favourable internal study is not enough to claim such excellence. The legislation refers in particular to recognised schemes, such as the EU Ecolabel or officially recognised type I environmental labelling schemes. The substantiation required therefore depends on the precise nature of the claim. An isolated improvement does not automatically turn a product into an environmental benchmark.
For a marketing team, the implications are tangible. “Greener packaging” offers little scope for verification and plenty for interpretation. Wording that specifies the proportion of recycled material, the component concerned and the calculation method may be more robust, provided it is accurate. The detail must be visibly presented alongside the message: an explanation buried on a technical page does not necessarily remedy a misleading headline.
The part must no longer stand for the whole
The directive also targets claims about an entire product or a company’s overall business when they concern only one aspect of the product or a specific business activity. This is a familiar pitfall: a partially recycled bottle becomes a “responsible” drink; a limited collection becomes a showcase for an entire retail brand. That leap is now explicitly targeted.
Advertising creatives must therefore regain a sense of scope. Is the claim about the container, the contents, manufacturing or transport? An industrial site or the group as a whole? This discipline also applies to images. A forest landscape or a pictogram can contribute to an implicit claim; their significance is assessed in the context of the message, not just its written statements.
Labels and offsetting: two shortcuts under pressure
Sustainability labels are another front. The legislation prohibits their display when they are not based on a certification scheme or established by a public authority. The little in-house seal designed to look like independent recognition thus loses its commercial appeal. Certification, however, does not authorise claims that go beyond what it actually covers.
On climate, the rule is particularly clear: claims based on greenhouse gas emissions offsetting that a product has a neutral, reduced or positive environmental impact in terms of emissions are prohibited. Buying carbon credits must therefore no longer serve as a shortcut to presenting a product as “carbon neutral”.
This does not amount to a ban on all communication about funding climate projects. But that contribution must be distinguished from the footprint of the product being sold. Brands will need to explain their emissions, their reductions and any funding separately, without suggesting that the latter cancels out the former. The narrative is less spectacular; it also becomes easier to understand.
Tomorrow’s promises create obligations today
Future environmental commitments are also subject to tighter rules. To avoid falling within the misleading practices targeted by the legislation, they must, among other things, be based on clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan. That plan must include measurable, time-bound targets, along with the elements needed to achieve them.
The framework provides for regular verification by an independent third-party expert, whose findings are made available to consumers. An announcement of long-term transformation cannot therefore remain an isolated statement in a corporate campaign. It requires a monitored pathway, resources and the ability to report on progress. The challenge is no longer simply to choose an ambitious date, but to explain the route towards it.
Organising the evidence within companies
A useful first step is to take stock of existing messages: packaging, product information sheets, advertisements, sales pitches and social media posts. Older creative assets are often a blind spot. A campaign may be corrected while a packaging photograph or a product listing reproduced by a retailer continues to circulate the original claim.
For each claim, a file should bring together its exact wording, its scope, the supporting evidence, its limitations and its validity date. Legal, communications, procurement and environmental teams must be able to work from the same version. Outdated supplier data or a comparison without an explicit reference point is enough to undermine even a carefully worded message.
The risk would be to respond with silence. This temptation, often called “greenhushing”, would also deprive consumers of useful information. Another approach looks more promising: make narrower claims, but communicate them better. Describing genuine progress, acknowledging what it does not resolve and making the evidence accessible can become signs of credibility rather than admissions of weakness.
What now? From the September 2026 deadline, attention is likely to shift towards enforcement practices, national interpretations and the first relevant decisions. Without anticipating how quickly these will emerge, one development seems likely: brands able to link every claim to up-to-date evidence will have an advantage. Environmental communication is not disappearing; it may finally learn to say precisely what it can substantiate.